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- September 20, 2017On September 20, 2017, the OCC, the Board of Governors of the Federal Reserve, and the FDIC issued a bulletin regarding the host state loan-to-deposit (LTD) ratios used to determine compliance with section 109 of the Riegle–Neal Interstate Banking and Branching Efficiency Act of 1994 (IBBEA) issued on June 21, 2017. These bulletin provided host state LTD ratios using data as of June 30, 2016, and...September 19, 2017On Tuesday, September 19, 2017, the CFPB took action against Top Notch Funding & two individuals associated with the company for allegedly lying about loan offerings to consumers waiting for settlement payments . Top Notch’s alleged victims included former National Football League players suffering from neurological disorders, victims of the Deepwater Horizon oil-rig disaster, and September...September 18, 2017On Monday, September 18, 2017, the CFPB took action against the National Collegiate Student Loan Trusts and their debt collector, Transworld Systems, Inc., for alleged illegal student loan debt collection lawsuits. The companies sued consumers for private student loan debt the companies could not prove was owed, or debt too old to litigate. The lawsuits allegedly relied on the filing of false or...September 18, 2017On Monday, September 18, 2017, the FDIC released a Financial Institution Letter encouraging depository institutions to consider all reasonable and prudent steps to assist customers in communities affected by recent storms. The agency recognized efforts to work with borrowers in impacted communities can be consistent with safe-and-sound banking practices and in the public interest. The FDIC's...September 15, 2017Preserve Arbitration: A Cost-Effective Alternative to Litigation How do consumers resolve disputes? Overwhelmingly, disputes between consumers and companies are resolved through informal channels and do not elevate to formal proceedings. Companies have strong incentives to maintain deep, well-informed, mutually satisfactory relationships with customers. Disputes rise to the level of a formal...September 15, 2017On Friday, September 15, 2017, the OCC released new enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with national banks and federal savings associations. All Cease and Desist Orders, Civil Money Penalty Orders, and Removal/Prohibition Orders are issued with the consent of the parties, unless otherwise indicated as a...September 14, 2017On Thursday, September 14, 2017, the CFPB announced that a no-action letter was issued to Upstart Network, Inc., who uses alternative data to make credit and pricing decisions. The no-action letter mandates that Upstart will regularly report lending and compliance information to the CFPB to mitigate risk to consumers and aid the Bureau’s understanding of the real-world impact of alternative data...September 14, 2017This week Capitol Hill weighed in heavily on the Equifax breach which reportedly affected more than 143 million customers. There were several letters from Members of Congress on both sides of the aisle in the House and Senate. The Senate Commerce Committee sent a letter to Equifax CEO Richard Smith inquiring of the scope and response to the breach. Democrats from the House Energy and Commerce...September 13, 2017On Wednesday, September 13, 2017, the federal bank regulatory agencies issued a joint notice of proposed rulemaking to amend their respective Community Reinvestment Act (CRA) regulations primarily to conform to changes made by the CFPB to Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). In addition, the draft proposal contains technical revisions and would remove obsolete...September 13, 2017On Wednesday, September 13, 2017, CBA submitted comments on the CFPB’s Request for Information about the small business lending market. Section 1071 of the Dodd-Frank Act, which amends the Equal Credit Opportunity Act (ECOA) to require financial institutions to compile, maintain, and report information concerning credit applications made by women-owned, minority-owned, and small businesses. Under...